31
August, 2005 An Options-Based Approach to Evaluating the Risk of Fannie Mae and Freddie Mac Deborah Lucas* Robert McDonald** Abstract Fannie Mae and Freddie Mac assume a significant amount of interest and prepayment risk and all of the credit risk for about half of the $8 trillion U.S. residential mortgage market. Their hybrid government-private status, and the perception that they are too big to fail, make them a potentially large, but largely unaccounted for, risk to the federal government. Measuring the size and risk of this liability is technically difficult, but important for the debate over the appropriate regulation of these institutions. Here we take an options pricing approach to evaluating these costs and risks. Under the base case assumptions, the estimated value of the guarantees is $7.9 billion over 10 years, with a combined .5 percent value at risk of $122 billion. We evaluate the sensitivity of these estimates to various modeling assumptions, and also to the regulatory regime, including forbearance policies and capital requirements. The analysis highlights the benefits, but also the challenges, of taking on options- based approach to evaluating the value of federal credit guarantees. *Northwestern University and the NBER. *Northwestern University This paper was prepared for the 2005 Carnegie Rochester Public Policy Conference. We thank Wendy Kiska, Marvin Phaup and David Torregrosa for their generous help and suggestions on this project, and Robin Seiler for useful conversations. We also thank conference participants, and especially Marvin Goodfriend, Andreas Lehnart, Wayne Passmore and George Pennachi for their detailed comments.

An Options-Based Approach to Evaluating the Risk of … · August, 2005 An Options-Based Approach to Evaluating the Risk of Fannie Mae and Freddie Mac Deborah Lucas* Robert McDonald**

  • Upload
    lekiet

  • View
    215

  • Download
    3

Embed Size (px)

Citation preview

August, 2005

An Options-Based Approach to Evaluating the Risk of Fannie Mae and Freddie Mac

Deborah Lucas* Robert McDonald**

Abstract Fannie Mae and Freddie Mac assume a significant amount of interest and prepayment risk and all of the credit risk for about half of the $8 trillion U.S. residential mortgage market. Their hybrid government-private status, and the perception that they are too big to fail, make them a potentially large, but largely unaccounted for, risk to the federal government. Measuring the size and risk of this liability is technically difficult, but important for the debate over the appropriate regulation of these institutions. Here we take an options pricing approach to evaluating these costs and risks. Under the base case assumptions, the estimated value of the guarantees is $7.9 billion over 10 years, with a combined .5 percent value at risk of $122 billion. We evaluate the sensitivity of these estimates to various modeling assumptions, and also to the regulatory regime, including forbearance policies and capital requirements. The analysis highlights the benefits, but also the challenges, of taking on options-based approach to evaluating the value of federal credit guarantees. *Northwestern University and the NBER. *Northwestern University This paper was prepared for the 2005 Carnegie Rochester Public Policy Conference. We thank Wendy Kiska, Marvin Phaup and David Torregrosa for their generous help and suggestions on this project, and Robin Seiler for useful conversations. We also thank conference participants, and especially Marvin Goodfriend, Andreas Lehnart, Wayne Passmore and George Pennachi for their detailed comments.

2

1. Introduction

Fannie Mae and Freddie Mac (F&F) assume a significant amount of interest and prepayment risk,

and all of the credit risk, for about half of the roughly $8 trillion U.S. residential mortgage

market. Their hybrid government-private status, and the likelihood that they would not be

allowed to fail because of the disruption it would cause to housing and financial markets, make

them a potentially costly risk to the federal government, and ultimately to taxpayers.

How large is this risk? The answer, although much debated in the literature (e.g., CBO (2001),

Jaffee (2003), Naranjo and Toevs (2002), Hubbard(2004), Passmore (2005), Stiglitz et. al.

(2002))1, remains poorly understood for a variety of reasons including limited regulatory

oversight and financial disclosure; and the inherent difficulties in modeling F&F’s risk exposure.

Compared to commercial banks and thrifts, F&F are lightly regulated. Their regulator, the Office

of Federal Housing Enterprise Oversight (OFHEO)2, cannot force prompt closure, has limited

modeling capabilities, and has very little latitude in adjusting capital requirements (Falcon

(2004)). The absence of an explicit federal guarantee means that no cost for F&F is recorded in

the federal budget, diluting the incentive for lawmakers to strengthen regulatory oversight or

increase legislative restrictions on risk-taking. F&F’s charter act exempts them from SEC

disclosure requirements, although they voluntarily comply with a number of its provisions for

equity. Modeling F&F’s risk exposure is complicated by its sensitivity to the poorly measured

tails of the distributions of interest rates and housing prices. Even if those risks could be

accurately assessed, F&F’s extensive and non-transparent use of derivatives and their

complicated liability structures make it impractical to model their risk exposure using reported

on- and off-balance-sheet quantities.

This paper takes an options-based approach to evaluating two related questions: what is the

insurance value of the implicit government guarantee to Fannie Mae and Freddie Mac, and how

does the distribution of possible losses change under alternative policy regimes? An advantage of

1 Few disinterested parties participate in this debate. Many of the studies that found costs to be low were commissioned by the GSEs (e.g., Hubbard (2004), Naranjo and Toevs (2002), and Stiglitz et. al. (2002)) whereas the studies that provided evidence for higher costs were under the auspices of federal government entities (e.g., CBO (2001) and Passmore (2003) is at the Federal Reserve Board of Governors.) Feldman (1999) surveys the results of older studies. 2 OFHEO is part of the Department of Housing and Urban Development (HUD), and agency whose primary mission is to promote affordable housing, not financial market stability.

3

this approach is that it requires making assumptions about a relatively limited set of variables –

firm asset variability, debt policy, and the trigger point for bankruptcy. It avoids having to

explicitly model F&F’s use of derivatives or the many sources of risk affecting their solvency,

since these factors are implicitly reflected in the distribution of firm asset and liability values.

Further, the option approach properly incorporates the price of market risk into the estimate of the

guarantee value. This is important because credit guarantees are equivalent to highly levered

positions in the assets of the guaranteed firms, and hence their value reflects their considerable

market risk (CBO (2004b)).

Despite the relative simplicity of an options-based approach, serious difficulties remain. These

include: whether the relatively short historical time series observed provides information about

the tails of the relevant statistical distributions; the extent to which F&F could and would adjust

their investment policy and debt in response to a rapid change in circumstances; and how quickly

F&F would be forced to cease operating in the event of serious financial distress. Because of

these uncertainties, rather than emphasizing a set of fixed assumptions, we focus on the

sensitivity of cost estimates and value at risk (VaR) to a variety of assumptions. The options-

based estimates also are compared to earlier estimates of guarantee value based on credit spreads

(Passmore (2005), and CBO (2001)), and also other volatility-based approaches (Stiglitz et. al.

(2002), Hubbard (2004)).

To briefly summarize the main findings, under the base case assumptions the combined value of

the implicit guarantee to F&F over a 10-year horizon is $7.9 billion. The value at risk at the .5

percent level is $74 billion for Fannie and $48 for Freddie. Extending the horizon to 25 years

increases the estimated guarantee value to $28 billion, and increases the value at risk to $89

billion and $60 billion respectively. A novel feature of the analysis is to increase the conditional

volatility of assets in periods of distress. We show that this significantly increases guarantee

value and value at risk, although it generates an undetectable increase in measured asset volatility

in time series data. Different policy options for limiting risk have very different effects.

Increasing capital requirements significantly lowers guarantee value, but has a relatively small

effect on catastrophic outcomes, as measured by the value at risk. Conversely, a reduction in

regulatory forbearance -- either in the form of more frequent monitoring or a more stringent

bankruptcy trigger -- has a minimal effect on guarantee value, but significantly reduces the

probability of a catastrophic outcome.

Deleted: 1

4

The remainder of the paper is organized as follows: In Section 2 we provide some background on

Fannie and Freddie. In Section 3 we introduce the basic model, discuss some of the critical

sensitivities, and lay out the alternative assumptions that are considered. Quantitative results are

presented in Section 4. Section 5 concludes with a discussion of policy options to reduce the risk

exposure from these entities.

2. Background

Fannie Mae and Freddie Mac were created by acts of Congress to provide liquidity and stability

in the home mortgage market. Fannie Mae was originally created as a wholly owned government

corporation in 1938, for the purpose of buying mortgages from originators and holding them in its

portfolio. It was converted into a GSE (Government Sponsored Enterprise) in 1968. Freddie Mac

was created in 1970 as part of the Federal Home Loan Bank System to purchase mortgages from

thrifts. Rather than holding mortgages in its portfolio, Freddie Mac pooled the mortgages and

attached a guarantee for credit risk. Claims to the cash flows from the insured mortgage pools

were sold to investors, creating mortgage-backed securities (MBS).

GSEs are hybrids of private corporations and federal entities. Although they are required to issue

their debt securities with the explicit statement that they do not bear a government guarantee,

their many federal ties convince investors otherwise, as evidenced by the relatively narrow spread

between GSE and Treasury debt issues compared to other financial institutions. According to the

Congressional Budget Office (2001), these federal connections include that they are chartered by

federal statute, exempt from state and local income taxes, exempt from the Securities and

Exchange Commission's (SEC's) registration requirements and fees, and may use the Federal

Reserve as their fiscal agent. The U.S. Treasury is authorized to lend $2.25 billion to each of

them. GSE debt is eligible for use as collateral for public deposits, for unlimited investment by

federally chartered banks and thrifts, and for purchase by the Federal Reserve in open-market

operations. GSE securities are explicitly government securities under the Securities Exchange Act

of 1934 and are exempt from the provisions of many state investor protection laws.

Concern about systemic risk has escalated along with the rapid growth of these enterprises (see

Frame and White (2005) for a recent survey). Their assets on-balance sheet grew rapidly through

2003, but fell slightly in 2004 to combined liabilities of $1.677 trillion (Table 1). The risk

represented by on-balance sheet holdings is considerably greater than for the MBS they

5

guarantee. Their mortgage holdings are financed largely with fixed rate debt of various

maturities, creating exposure to interest rate and prepayment risk that is partially hedged with

derivatives. The exposure on MBS is limited to credit risk, which causes little concern because of

the collateral value of houses and historically low credit losses. Nevertheless, a large negative

shock to house prices could lead to significant losses on the $2.255 trillion of MBSs guaranteed

by the two firms, as well as on their balance sheet holdings. A further concern is that the implicit

government subsidy accrues to F&F’s shareholders rather than to the housing market.

Historically these firms have been extremely profitable for their investors (see Figure 1). The

returns on the two firms are highly correlated, confirming that they are affected by common risk

factors. The correlation in monthly data from October 1989 to December 2004 is 79.5 percent.

2.1 Risk Experience and Disclosure

The potential susceptibility of the GSEs to economic shocks, particularly when mortgages are

held on-balance-sheet rather than securitized, was demonstrated during the late 1970s and early

1980s. As for the savings and loan industry, high and volatile interest rates weakened Fannie Mae

as the value of 30-year mortgages fell and the cost of financing increased. Because interest rate

and prepayment risk are transferred to the buyers of MBS, Freddie Mac was much less exposed to

interest rate risk during this earlier time period, and hence was less adversely affected than was

Fannie Mae.

This experience caused Fannie Mae to take measures to reduce balance sheet risk exposure, and

beginning in the early 1980s, it rapidly increased its reliance on MBS. For both companies,

however, the ratio of mortgages held in portfolio to MBSs guaranteed only against credit losses

grew rapidly in the 1990s, and has flattened out since 2000 (see Figure 2, which is based on Table

1).

6

TABLE 1. OUTSTANDING MBS AND DEBT, YEAR-END 1985-2004 (In billions of dollars)

Fannie Mae Freddie Mac MBSa Debtb MBSa Debtb

1985 55 94 100 13 1986 96 94 169 15 1987 136 97 213 20 1988 170 105 226 27 1989 217 116 273 26 1990 288 123 316 31 1991 355 134 359 30 1992 424 166 408 30 1993 471 201 439 50 1994 486 257 461 93 1995 513 299 459 120 1996 548 331 473 157 1997 579 370 476 173 1998 637 460 478 287 1999 679 548 538 361 2000 707 643 576 427 2001 859 763 653 578 2002 1,029 851 749 666 2003 1,300 962 773 740 2004 1,403

945

852

732

SOURCE: Congressional Budget Office based on data from the Department of Housing and Urban Development’s Office of Federal Housing Enterprise Oversight, and the Federal Housing Finance Board. The 2004 numbers are based on data from Fannie Mae and Freddie Mac. a. MBSs = mortgage-backed securities issued by the enterprise; excludes holdings of the enterprise’s own MBSs held in its portfolio. These are off-balance sheet, with exposure only to credit risk. b.On-balance sheet debt, financing primarily mortgages with exposure to interest rate, pre-payment, and credit risk. * As of June 30, 2004, data from FHLB Office of Finance.

7

Figure 1: Cumulative Monthly ReturnsSept. 1989 - Dec. 2004

02468

10121416

Aug-89

Aug-90

Aug-91

Aug-92

Aug-93

Aug-94

Aug-95

Aug-96

Aug-97

Aug-98

Aug-99

Aug-00

Aug-01

Aug-02

Aug-03

Aug-04

Date

Ret

urns Fannie

FreddieS&P

Figure 2: Ratio of Outstanding Debt to MBS

0.0020.0040.0060.0080.00

100.00120.00140.00160.00180.00

1985

1987

1989

1991

1993

1995

1997

1999

2001

2003

Year

Per

cent FNM ratio

FRE ratio

Although the growth in portfolio holdings appears to represent a considerable increase in risk

taking over the last decade, Fannie Mae and Freddie Mac take measures to hedge their exposure

using derivatives such as swaps, swaptions, and callable debt, as well as dynamic hedging

strategies (see Jaffee (2003) for a more detailed discussion). The effectiveness of these hedges is

difficult to evaluate because of the very limited risk disclosure by both firms, and because there

8

has not been a shock large enough to test the functioning of the derivatives markets upon which

the hedges rely.

One measure of risk exposure that both firms report is their duration gap, which measures the

difference in the sensitivity of portfolio assets and liabilities to changes in interest rates. For

instance, a 6 month duration gap means that a 1 percent increase in interest rates will cause the

value of assets to fall by about ½ percent more than the value of liabilities, thereby eroding

capital by an amount equal to ½ percent of assets. The measure proved informative in September

of 2002, when Fannie reported that its duration gap had ballooned to 14 months, well outside its

target range of less than 6 months. Capital markets responded to this information, as reflected in

the increase in the implied volatility of Fannie’s equity value at that time (see Figure 3). Implied

volatilities are derived from options price data using an options pricing model. The return of

implied volatilities to normal levels suggests that the concerns raised by the event were short-

lived.

F&F also present a “fair value balance sheet” designed to give a more accurate picture of their

economic situation than their official balance sheet that reflects accounting conventions (such as

mixing market and book values) that can be misleading. While Freddie reports its fair value

quarterly, Fannie reports it only annually.

9

Although F&F are exempt from SEC registration requirements and fees, recently Fannie opted to

register their common stock with the SEC, and Freddie has expressed the intention to follow. In

doing so, information from Form 10k and other mandatory disclosures for publicly traded firms

will become available, but these reports have only limited quantitative information on derivatives,

and will add little to disclosures already made by the enterprises. Neither registers their debt or

MBS securities with the SEC.

Credit ratings provide an additional external evaluation of default risk, and have been used in

some past studies as the basis for estimating the government subsidy (CBO (2001), Passmore

(2005)). The ratings agencies have refined their analysis in recent years, and now make a clear

distinction between a rating that reflects the risk to investors in agency debt securities and the

companies’ stand-alone risk. Moody’s rating, taking into account the regulatory regime and

implicit guarantee, is AAA for the unsecured debt of both firms, and P-1 for short-term issues.

However the “bank financial strength rating,” which corresponds more closely to a measure of

the risk to the government, was recently lowered to B+ from and A- for Fannie. For Freddie the

bank financial strength rating is A-. The credit default swap market offers another piece of data

on how the risk of F&F compare to other financial institutions. Credit default swaps (CDS) are

Figure 3: The Effect of the 9/02 Spike in Fannie's Duration Gap on Implied Volatility Differentials

0

0.1

0.2

0.3

0.4

0.5

0.6

0.7

7/1/2002 8/1/2002 9/1/2002 10/1/2002 11/1/2002 12/1/2002

Date

Implied volatility

Fre 30-day implied vol FNMA 30-day implied vol

10

derivatives that make a payment to the protection buyer if there is a default event on an

underlying security, in exchange for a fixed premium payment to the protection seller. Recent

data from the CDS market suggest that F&F are perceived to have default risk similar to other

large financial institutions.

2.2 Regulatory Controls on Risk

Regulation limits risk-taking through two main mechanisms: restrictions on investments and

minimum capital requirements. F&F’s charter restrict their investments primarily to conventional

mortgages. They predominantly hold and securitize conforming mortgages. The definition of a

conforming mortgage is based on loan size, the loan to value ratio, and property type. The

conforming mortgage ceiling is indexed to house prices and hence has been increasing rapidly.

The conforming limit rose from $252,700 in 2000 to $359,650 in 2005. That limitation excludes

F&F from only about 10 to 20 percent of the residential mortgage market. In fact the fraction of

the market they intermediate has grown more rapidly than the available conforming mortgages, as

the share of non-GSE competitors for conforming mortgages has decreased over time. The loan

to value ratio on a conforming mortgage cannot exceed 80 percent, unless supplemental insurance

or some other permissible guarantee mechanism is obtained. The vast majority of conforming

mortgages are for single family homes, but dwellings with up to four units also can qualify as

conforming.

F&F are required to hold a minimum amount of capital as a buffer against adverse shocks. The

fixed part of the requirement stipulates capital equal to 2.5 percent of on-balance sheet assets, and

.45 percent of off-balance sheet obligations and assets. Additional capital is required if they fail

to pass a stress test that subjects them to several hypothetical large and sustained interest rate

changes over ten years, and also a severe credit event. These capital requirements have recently

become a binding constraint on Fannie Mae, although both firms generally have maintained

slightly more than the regulatory minimum capital. As for commercial banks with deposit

insurance, economic theory predicts that to maximize the value of the implicit guarantee F&F

would manage liabilities so that capital remains close to the regulatory minimum.

11

3. The Model

The options-based approach to modeling credit guarantees is based on the insights of Sharpe

(1976) and Merton (1977), that such insurance can be valued as a put option on the assets of the

underlying firm’s assets. A put option gives the holder the right but not the obligation to sell an

asset at a pre-specified strike price, and will be exercised if the market value of the underlying

asset falls below the strike price. In the case of a firm with just one maturity of zero coupon

guaranteed debt outstanding, the strike price of the option is the face of the debt, and the maturity

of the option equals the maturity of the debt.

This approach, modified to take into account complications such as the term structure of debt

obligations and state-contingent triggers for bankruptcy, is an alternative to traditional predictors

of bankruptcy risk that rely on financial ratio analysis. KMV, a subsidiary of Moody’s, has

invested considerable resources in developing it as a commercial tool, and provides a clear

description of the basic method (Crosbie and Bohn (2003)). Moody’s now uses this information

as an input in some of their credit ratings.

For pricing F&F’s implicit guarantee, our analysis uses Monte Carlo simulation with risk neutral

probabilities, which accommodates a variety of assumptions about debt policy, time variation in

risk, and regulatory regime. Monte Carlo valuation uses the risk-neutral distribution of outcomes,

but we also estimate the true distributions in order to estimate the distribution of possible

observed losses.

3.1 Evolution of Assets.

The standard abstraction for the evolution of asset value is that the expected return on existing

assets reflects the market risk of those assets (e.g., the asset beta), and that the returns are log-

normally distributed.3 In addition, firm assets may increase due to purchases financed with

additional debt and equity issues, or retained earnings. In a risk-neutral representation, returns

are log-normally distributed but on average equal the risk-free rate. The risk-neutral discrete time

representation of the evolution of assets in the Monte Carlo can be represented as:

3 The log normal representation is standard, and allows a simple transformation between the actual and the risk-neutral measure. Some have suggested that financial institutions bear fatter-tailed risks. Although we do not consider this possibility directly, we do consider the possibility of higher asset volatility in the sensitivity analysis in part as a proxy for fatter tails.

12

(1) ⎥⎦

⎤⎢⎣

⎡+−−+=+ hh

AE

grExpAA AAo

otftht εσσδ )5.( 2

where h is the time step, subscripts represent time, E is equity, A is assets, rf is the risk-free rate,

gt is externally financed firm asset growth, δ is the dividend yield on equity (hence 0

0AEδ is the

dividend yield on assets), σA is the volatility of firm assets, and ε is a draw from a standard

normal distribution under the risk neutral probability measure. The same evolution in terms of

the true probability distribution can be written as:

(1a) ⎥⎦

⎤⎢⎣

⎡+−−+=+ hh

AE

grExpAA AAo

otAtht εσσδ ˆ)5.( 2

In equation (1a) ε̂ is a draw from a standard normal distribution under the true probability

measure, and rA is the risk-adjusted required return on assets. These representations for firm

assets should be interpreted as the present value of all expected future cash flows, including those

from on- and off-balance sheet activities. The drift is equal to required returns (equal to the risk-

free rate under the risk-neutral measure, and the risk-adjusted return under the true probability

measure) net of payouts.

Time variation in the assumed volatility of assets can significantly affect cost estimates, with

periods of high volatility having a large influence on guarantee value. Consideration of the

possibility of time variation is important also because of the relatively short historical time series

of available data, and the limited number of large shocks observed. The effect of time variation

in volatility, particularly increased volatility during times of financial distress, is considered in the

sensitivity analysis.

The initial market value and volatility of firm assets must be estimated since it is not directly

observable. The market value of firm assets is the sum of the market value of liabilities and

owners equity. Although many of the liabilities of Fannie and Freddie are liquid and publicly

traded, the complexity of the liability structure makes it difficult to directly estimate their

outstanding market value. Further, the traded debt prices reflect the value of the implicit

13

guarantee, whereas we also are interested in the market value of the liabilities in the absence of

insurance. Using Merton’s framework, we can use options pricing theory to impute the value and

volatility of firm assets from the value and volatility of firm equity. The idea is that equity can be

valued as a call option on the firm’s assets, with a strike price equal to the future book value of

liabilities, according to:

(2) )1()()( 21qTTfrqT eAdNXedNAeE −−− −+−=

(3) 11 )]1()([ −−− −+= qTqT

EA eedNAEσσ

)/(])5.()/[ln( 5.21 TTqrXAd AA σσ+−+=

5.

12 Tdd Aσ−=

where T is the maturity of liabilities, and X is the strike price, q=0

0AEδ is the payout rate of

assets, and all values are as of time 0. Equation (3) comes from the fact that in the Merton model,

.AE EA

AE σσ ⎟

⎠⎞

⎜⎝⎛

∂∂= Given the other parameters, equations (2) and (3) are solved

simultaneously for A and σA.

Although we model asset risk abstractly through asset volatility imputed from equity value and

volatility, it is worth enumerating the types of risk F&F are exposed to. These risks can be

broken into three broad categories: interest rate risk, credit risk, and other risks. An advantage of

the options pricing approach is that stock price volatility is arguably the most comprehensive

measure of risk, and perhaps the only available measure that includes all three sources.

Interest rate risk, and the accompanying prepayment and extension risk that arise due to the

prepayment option on residential mortgages,4 has received the most attention. As discussed by

4 Both prepayment risk and extension risk arise from the option to prepay mortgages. Prepayment risk is due to rapid prepayments in a falling interest rate environment, whereas extension risk results from mortgages remaining outstanding longer than predicted at the time of pricing in a rising interest rate environment. The two risks together give mortgages the property of negative convexity, whereby small changes in interest rates cause a reduction in value relative to an option-free bond with comparable duration.

14

Jaffee (2003), interest rate related risk is absent for the MBS they guarantee, since it is borne by

the holders of those securities. The mortgages held on balance sheet, to the extent they are not

hedged through the debt structure and the use of derivatives, are the source of interest rate risk.

Hedges protect F&F from small to moderate rate changes, but the results of stress tests suggest

that they are exposed to large and rapid movements in rates.

Credit risk is present both from mortgages held on balance sheet, and from the MBS they

guarantee. Credit risk on conforming mortgages is mitigated by the restriction that the loan to

value ratio not exceed 80 percent. On MBS, F&F charge approximately 20 bps for this insurance.

Historically credit losses have been modest, and more than covered by these fees. Nevertheless,

recent concern about regional housing bubbles and the possibility that higher interest rates could

trigger a crash suggest that credit risk could become more significant. It is notable that although

F&F actively manage interest rate risk with derivatives, it does not appear they have tried to

directly hedge this risk, for example by creating and selling derivatives on mortgage credit risk.

Thus, their levered position (via the MBSs they guarantee) in credit risk appears to be entirely

retained.

The “other risks” category is a catch-all for political risk, accounting risk, fraud, liquidity risk,

model risk, counterparty risk in the derivatives market, etc. These other risks are potentially quite

important, although they are emphasized less often in the academic literature and are more

difficult to quantify. Political risks include a weakened public perception of the guarantee value,

which could increase the cost of funds and lower market capital. It also includes the possibility of

legislation that restricts growth or increases competition, reducing franchise value. Seiler (2003)

stresses the importance of political risk, and uses an event study methodology to show its effect

on stock price. Liquidity risk is related to political risk, as the market for Fannie and Freddie

issues might lose liquidity in the event of an unanticipated government action. Accounting

misrepresentations or fraud not only may diminish equity capital, but also can prolong the time

between when a problem arises and is recognized, increasing the severity of losses. The risk

associated with accounting irregularities is evidenced by the recent restatement of $9 billion of

earnings by Fannie Mae, and the subsequent precipitous drop in their stock price.

3.2 Evolution of Liabilities

15

In the simplest form of the Merton model, liabilities have a single fixed maturity and are constant

over the life of the option. This assumption is unrealistic for most firms, and especially so for

highly leveraged financial institutions. Theoretically, debt should be managed to maximize the

value of equity, and closed form solutions for optimal or stationary debt policy have been derived

for a few special cases (e.g., Leland (1994), Collin-Dufresne and Goldstein (2001)). In the case

of insured financial institutions, the standard argument is that holding equity at the regulatory

minimum maximizes the value of the government guarantee, particularly as firms become

distressed. Little is known, however, about how Fannie and Freddie would manage their

liabilities and hedging strategies in the event of sudden financial distress, or the speed with which

they could adjust their liability positions.

To examine the sensitivity of cost estimates to different dynamic liability management strategies,

we assume that the book value of liabilities adjusts towards a target liability to asset ratio at

several different adjustment rates. Liabilities, L, evolve according to:

(4) [ ] tthr

ttthgr

tht AAeLhIeLL dtd /*)( −+= ++ λαγ

where αt is the annual rate of adjustment, which may be state dependent, λ* is the target liability

to asset ratio, and It is an indicator variable that equals one in a period where liabilities are

adjusted, and 0 otherwise. Liabilities grow at a rate rd to cover promised coupons. In addition, a

fraction γ of externally financed growth is supported by debt. This representation applies to both

the actual and risk-neutral measure, but the realized paths differ because the return on debt and

externally financed growth take on different values in each instance.

Computationally it would be straightforward to add volatility to liabilities in this model. We

maintain the assumption of non-stochastic liabilities, however, because the estimated volatility of

assets implicitly captures volatility arising from all sources, including liabilities.

3.3 Modeling the Trigger for Insolvency

In the basic, continuous time Merton model, bankruptcy is triggered by the market value of assets

falling below some trigger value. If the trigger value were equal to the book value of liabilities,

the cost of a credit guarantee would always be zero, since debt holders take over the firm at the

16

point where it equals the value of their claim. In reality managers tend to postpone bankruptcy,

and creditors recover far less than the promised value of their claims. The conditions under

which managers seek the protection of bankruptcy courts varies considerably, leading to wide

variations in recovery rates, even within a single seniority class or industry.

Modeling the bankruptcy trigger for Fannie and Freddie is further complicated by the regulatory

situation. They do not operate under the U.S. bankruptcy code. Their regulator, OFHEO, only

has the powers of a conservator, not a receiver (Carnell (2004)). This means that although

OFHEO has some control, it does not have the authority to close F&F down, nor to pay off

creditors.

Several insolvency triggers are commonly used in models that take into account more

complicated liability structures and trigger strategies (e.g., see Crosbie and Bohn (2003)). One is

that the firm is liquidated when the market value of assets falls below the level of current

liabilities plus half of the book value of long-term liabilities. Another is that the market value of

assets falls below a fraction, sometimes taken to be 70 percent, of the total book value of

liabilities. We consider a variety of trigger levels based on the value of assets relative to book

liabilities. The distinction between long and short-term liabilities is less meaningful for F&F than

for many other firms because of the constant maturity conversion taking place through the

derivatives market, so no distinction is made on that basis.

We assess the cost of a drawn-out reorganization or closure process -- which might also be

described as regulatory forbearance -- in two ways. First, we use the ratio of assets to liabilities

that triggers bankruptcy to represent forbearance, with a higher trigger level representing a more

stringent regulatory policy. Second, following Merton (1978) on deposit insurance, we assume

that the trigger for bankruptcy is only checked periodically. The longer the time between

“audits,” the greater the probability that the financial condition of a distressed firm will have

deteriorated, and the greater the cost to the government contingent upon bankruptcy. The

probability of bankruptcy, however, may be lower under the assumption of less frequent auditing

when asset returns have a positive drift. This offsetting effect makes the net cost of forbearance

in the form of lower frequency audits indeterminate. We consider a variety of audit frequencies

in the sensitivity analysis.

17

An element of the cost associated with a delayed closure procedure is that asset volatility could

increase significantly, for reasons such as unusually volatile markets, reduced availability of

derivatives for hedging, or a purposeful increase in risk-taking to gamble to regain solvency.

This increase in volatility is unlikely to be observed in historical data, both because its occurrence

is a low probability event, and because it is likely to persist for relatively short periods of time

when it does occur. The quantitative analysis below suggests that this may be the most important

cost of forbearance.

4. Results

4.1 Initial Values

Inputs into (2) and (3) to estimate the initial value of firm assets and asset volatility are

summarized in Table 2. All values are based on year-end 2004 data, except the equity volatility,

which is based on its historical average. The Table also shows the resulting estimates of asset

value and volatility. Since the liabilities have multiple maturity dates, the maturity of the option

is based on the average maturity of reported liabilities, and the strike price is the future value of

total reported book liabilities. The volatility of equity is a critical input, serving as a sufficient

statistic for the net effect on risk of all on- and off-balance-sheet activities including interest rate

risk, derivatives used in hedging strategies, and MBS guarantees. Estimated volatility varies

considerably over time. For instance, for Fannie Mae it averages 31 percent from January 4,

1996 to December 31, 2004, but ranges from 16.7 percent to 60 percent (see Figure 4).

Figure 4: Fannie Mae Implied Volatility

00.10.20.30.40.50.60.7

1/4/

1996

1/4/

1997

1/4/

1998

1/4/

1999

1/4/

2000

1/4/

2001

1/4/

2002

1/4/

2003

1/4/

2004

date

vol

implied vol

18

The model generates an estimated asset volatility of only 2.06 percent for Fannie Mae, and 1.92

percent for Freddie Mac. The sensitivity analysis reveals that the cost estimates and distribution

of losses are very sensitive to this parameter.

Table 2: Market Value and Volatility of Assets -- Estimates and Inputs (dollar values in millions) FANNIE MAE FREDDIE MAC Market Value Assets

$1,026,194 $793,670

Volatility Assets 0.0206 0.0192

Market Value Equity

$68,924 $50,740

Volatility Equity 0.3 0.3Book Value Liabilities

$945,000 $731,697

Wtd. Maturity Liabilities

2.65 3.05

Dividend Yield on Equity

0.0225 0.0178

4.2 Base Case

The parameters for the base case simulations are reported in Table 3, with a brief explanation of

what they represent. This case is not necessarily the most likely, but seems a reasonable starting

point. The estimate is based on a 10-year time horizon, mitigating the greater estimation error

and model uncertainty in longer-term projections. Asset volatility is assumed to increase to four

times its normal level when assets fall to 101 percent of liabilities, representing increased

volatility in periods of financial distress. Management and regulatory decisions (debt adjustment

and solvency determination) are evaluated at a quarterly frequency, while assets returns are

calculated at a monthly frequency. Liabilities adjust gradually and asymmetrically towards their

target level -- 80 percent per year adjustment up versus 40 percent per year adjustment down.

The asymmetry reflects that it is more difficult to rapidly reduce liabilities when asset values are

declining than it is to increase them when times are good. To reflect the historically high rate of

asset growth, assets are assumed to grow at a rate equal to their realized return net of dividends,

plus an additional 6 percent annually when the target capital ratio is met or exceeded. The

19

external growth is financed entirely with an increase in debt. When capital is below the target

level there is no additional debt-financed growth.

Table 3: Base Case Parameter Values Short Name Value Description ____ . Fannie Mae FAinit $1,026,194 initial market value of assets ($ millions) FLinit $ 945,000 initial book value of liabilities ($ millions) MVEquity $68,924 initial market value of equity ($ millions) dividend yield 0.0225 Freddie Mac FAinit $793,670 initial market value of assets ($ millions) FLinit $731,697 initial book value of liabilities ($ millions) MVEquity $50,740 initial market value of equity ($ millions) equity dividend yield 0.0178 FAvol 0.0192 firm asset volatility during normal conditions FAvol_h 0.0768 firm asset volatility in high volatility state Common Values rf 0.025 risk free rate rd .0275 promised return on debt FAer_a 0.03307 firm asset expected return (actual) FAer 0.025 firm asset expected return (risk-neutral) FAvol 0.0206 firm asset volatility during normal conditions FAvol_h 0.0824 firm asset volatility in high volatility state FLrate_d 0.4 / 4 quarterly adjustment of liabilities to lower target FLrate_u 0.8 / 4 quarterly adjustment of liabilities to higher target growth 0.06 externally financed growth if enough capital growth_trig .93 if target liability to asset ratio met, then growth growth_debt 1 proportion of external financing that is debt trigger 0.98 bankruptcy trigger assets/liabilities trig_volh 1.01 trigger of assets/liabilities for higher volatility look 4 frequency of checking bankruptcy trigger per year look_l 4 frequency of updating debt FLFAtarget .93 target liability to asset ratio newFLFA 1 proportion of debt financed exogenous asset growth nmonte 20,000 number of Monte Carlo simulations nyear 10 number of years in each simulation run nfreq 12 time steps per year

20

The results of the base case Monte Carlo simulations are summarized in Table 4, where we report

the guarantee value, the risk neutral and actual default probabilities, and the value at risk (VaR) at

the 0.5 percent level under the actual probability measure. The risk neutral default probability is

always greater than the actual default probability due to the effect of market risk; the risk neutral

result is presented to illustrate the magnitude of this difference. The true default probabilities are

consistent with Moody’s historical 10-year cumulative default probabilities for corporate bonds

with comparable ratings -- for instance bonds rated Baa2 have a cumulative default probability

over 10 years of 5.5 percent. Value at risk measures the worst outcome in terms of present value

of the cost of the government payoff at the one percent level over the 10 years of the simulation

period. The VaR is more relevant to the question of systemic risk than the guarantee value, since

it gives a sense of the size of rare but catastrophic outcomes. Figures 5 and 6 show the

distribution of the present value of costs conditional upon default for each firm in the base case.

Table 4: Base Case Results

Guarantee Value ($ billions)

10-year default probability (actual)

10-year default probability (risk neutral)

VaR at .5 percent ($ billions)

Fannie Mae 5.14 .064 .152 74

Freddie Mac 2.78 .042 .115 48

Figure 5: Present Value Cost of Fannie Mae Conditional on

Default

010203040

2000

030

00040

00050

00060

00070

00080

00090

000

1000

00More

($ millions)

perc

ent

21

Figure 6: Present Value Cost of Freddie Mac Conditional on

Default

010203040

2000

030

000

4000

050

000

6000

070

000

More

($ millions)

perc

ent

4.3 Sensitivity and Policy Analyses 4.3.1 Asset Volatility

The experiments reported in Table 5 show that assumed asset volatility is a critical sensitivity.

The guarantee cost, the probability of default, and the VaR all increase rapidly in volatility over

the range considered. Results for both firms are reported for a fixed 2.5 percent and 3 percent

asset volatility. All other parameters are as in the base case.

Table 5: The Effect of Increased Asset Volatility

Guarantee Value ($ billions)

10-year default probability (actual)

VaR at .5 percent ($ billions)

Fannie Mae (.025 vol) 9.60 .130 100

Freddie Mac (.025 vol) 7.24 .126 80

Fannie Mae (.03 vol) 15.43 .215 126

Freddie Mac (.03 vol) 12.03 .216 97

An alternative to higher steady state volatility that increases guarantee value without significantly

increasing the probability of default is to increase the conditional volatility when the enterprises

22

become distressed. In general, higher conditional volatility might be attributable to the same

factors that caused financial distress, or it could result from deliberate risk-taking in an effort to

avoid insolvency. To examine this effect, the non-distress volatilities and all other parameters are

set to base case values. In the first variation conditional volatility is held constant at the base case

non-distress level. In the second variation, for an asset to liability ratio between the default

trigger of 98 percent and 101 percent, volatility is assumed to increase six-fold for each firm.

These values bracket the base case, in which volatility increases fourfold for the same range of

liability ratios. The results are reported in Table 6.

Table 6: High Volatility Conditional on High Leverage

Guarantee Value ($ billions)

10-year default probability (actual)

VaR at .5 percent ($ billions)

observed average vol

Fannie (0x high vol) 4.32 .020 31 .0206

Freddie (0x high vol) 2.40 .009 19 .0192

Fannie (6x high vol) 5.39 .065 96 .0210

Freddie (6x high vol) 2.84 .043 63 .0195

What is most striking about results in the high conditional volatility case in Table 6, as compared

to the results with the smaller but constant increases in volatility considered in Table 5, are

similarly high VaRs but much lower 10-year default probabilities. The difference is explained by

the fact that higher conditional volatility tends to make losses more severe when bankruptcy

occurs, but distress events remain rare. Also noteworthy is that the observed average volatility

(calculated across simulations and time periods) is only slightly higher than the volatility during

normal periods (last column in Table 6). The low observed volatility occurs because periods of

heightened volatility are rare and short-lived. This suggests that time variation in volatility may

be an important, but intrinsically unobservable, factor driving guarantee costs and systemic risk.

4.3.2 Liability Rules

How the fixed portion of liabilities (equated initially to the book value of on-balance sheet debt)

should vary over time with firm asset value is an open but important question. Mathematically it

affects the results because it is the reference point for the bankruptcy trigger. In the base case, the

difference in difficulty of adjusting debt up in good times versus down in bad times is reflected in

differential adjustment speeds of 80 percent per year towards the target versus 40 percent per year

Deleted: 1

23

towards the target. The sensitivity analysis reported in Table 7 shows the effect of two

alternatives: a symmetric rate of adjustment up and down of 25 percent, and a severe asymmetry

of 85 percent up and 15 percent down. As expected, greater asymmetry, and reducing the rate at

which liabilities can be reduced with or without asymmetry, increases the guarantee cost

significantly – for these parameters by as much as a factor of two relative to the base case.

Table 7: Alternative Debt Adjustment Rules

Guarantee Value ($ billions)

10-year default probability (actual)

VaR at .5 percent ($ billions)

Fannie (symmetric, +.25/-.25) 7.20 .075 71

Freddie (symmetric, +.25/-.25) 4.50 .056 50

Fannie (asymmetric, +.85/-.15) 9.96 .10 79

Freddie (asymmetric, + .85/-.15) 6.26 .075 54

4.3.3 Changing Capital Requirements

The effect of altering capital requirements can be represented by a change in the target ratio of

liabilities to assets. In the base case the target ratio is set to .93, slightly higher than the initial

estimated ratio. Actual capital requirements are more complicated than a simple ratio of the

market value of equity to the market value of assets, as they depend on book values and stress test

results. How tightly management can and does maintain a target ratio also is not observable.

Table 8 shows the effect of increasing the assumed target ratio to .95 and decreasing it to .91,

with all other parameters as in the base case. As would be expected of such highly levered

institutions, relatively small changes in the target leverage ratio have an enormous impact on the

guarantee value and risk exposure, suggesting that this is a powerful policy lever for controlling

government risk exposure.

Table 8: Changing Capital Requirements

Guarantee Value ($ billions)

10-year default probability (actual)

VaR at .5 percent ($ billions)

Fannie (target L/A = .91) 1.93 .023 54

Freddie (target L/A = .91) 1.01 .014 33

Fannie (target L/A = .95) 11.14 .149 97

Freddie (target L/A = .95) 6.70 .108 70

24

4.3.4 Growth and Horizon

In the past decade F&F’s portfolio growth rate exceeded that of the conforming mortgage market

as they captured an increasing market share. Growth rates going forward likely will be lower,

both because market share is bounded and because of regulatory pressures to restrain growth. In

the base case we assume that both companies grow according to the rate of return on their assets

net of dividends, which averages about 3 percent, and that if the capital ratio is at or above its

target, assets increase an additional 6 percent, funded entirely by new debt issues. A natural

question is what happens to estimated costs if debt-funded growth is higher or lower than initially

assumed? Table 9 reports what happens when externally financed growth is assumed to be 4

percent or 8 percent, with all other parameters as in the base case. While guarantee value and

VaR both increase with the growth rate, the increases are modest. The small effect can be

attributed to the assumption that externally financed growth only occurs if the target capital ratio

is satisfied.

Table 9: Varying Exogenous Growth

Guarantee Value ($ billions)

10-year default probability (actual)

VaR at .5 percent ($ billions)

Fannie (4% growth) 4.58 .057 68

Freddie (4% growth) 2.56 .039 48

Fannie (8% growth) 5.38 .068 79

Freddie (8% growth) 2.88 .043 52

The analysis focuses on a 10-year horizon to avoid the greater approximation errors at longer

horizons. For comparison to other studies, and to illustrate the effect of horizon on cost, Table 10

reports results under the base case assumptions, but with a 25-year horizon. In comparison to the

10-year horizon, the guarantee value increases by a much larger percentage than the VaR because

while the number of bankruptcy events increases with horizon, the severity of the events is

limited by the assumption that liabilities revert toward a target level and by the closure rule.

25

Table 10: Costs Over 25 Year Horizon

Guarantee Value ($ billions)

25-year default probability (actual)

VaR at .5 percent ($ billions)

Fannie Mae 17.41 .199 89

Freddie Mac 10.67 .136 60

4.3.5 Forbearance

In the base case regulators are assumed to monitor the enterprises quarterly, and to shut them

down if the ratio of assets to liabilities falls below the bankruptcy trigger of .98. One way to

model greater forbearance is to decrease the frequency at which the bankruptcy trigger is

monitored. Another approach is to lower liability to asset ratio that serves as the bankruptcy

trigger.

The effects, shown in Table 11, of varying the monitoring frequency are based on a 25-year

horizon. Table 10 serves as the base case for comparison, as it is also for a 25-year estimation

period. The longer horizon permits a more accurate assessment of the effect of changing the

monitoring frequency. The results indicate that increasing the frequency of monitoring

dramatically reduces the VaR – going from semi-annual to monthly monitoring more than cuts it

in half. With more frequent oversight, regulators are able to cut off rapidly mounting losses,

significantly reducing the likelihood of a catastrophic event. Increasing monitoring frequency,

however, has a relatively small effect on the estimated guarantee value. In fact, for some

parameters, increasing monitoring frequency has the effect of slightly increasing guarantee value.

The reason is that while more frequent monitoring tends to reduce costs conditional on hitting the

trigger, an offsetting effect is that it increases the frequency with which the trigger is hit.

Table 11: Varying Monitoring Frequency

25-year Guarantee Value ($ billions)

25-year default probability (actual)

VaR at .5 percent ($ billions)

Fannie (monthly) 16.72 .230 54

Freddie (monthly) 10.77 .160 37

Fannie (semi-annually) 17.83 .172 121

Freddie (semi-annually) 10.96 .122 80

26

For the bankruptcy trigger, we maintain all base case assumptions (returning to a 10-year horizon

and quarterly monitoring), but bracket the base case assumption that an asset to liability ratio of

.98 triggers bankruptcy, setting the trigger to .97 and .99. As with the frequency of monitoring,

and for the same reasons, changing the bankruptcy trigger has an insignificant effect on guarantee

value, but a very large impact on the VaR and the probability of catastrophic losses.

Table 12: Varying Bankruptcy Trigger

Guarantee Value ($ billions)

10-year default probability (actual)

VaR at .5 percent ($ billions)

Fannie (asset/liability .97) 4.63 .051 85

Freddie (asset/liability .97) 2.52 .035 62

Fannie (asset/liability .99) 4.43 .072 52

Freddie (asset/liability .99) 2.61 .049 33

4.4 Comparisons to Previous Studies

Many of the results in the literature cannot be directly compared because they vary with regard to

the time period covered, whether the estimate is a present value or an annual flow number, and

exactly what the cost represents. Nevertheless, it is useful to make some comparisons of these

estimates with those of other studies.

Several authors have estimated the value of the implicit government guarantee by comparison of

yields on F&F debt with issues from similarly rated financial institutions of equal maturities.5

The subsidy on MBSs guaranteed was similarly found by looking at comparable guarantees made

by private entities. For instance, CBO (2004a) reports an estimated present value subsidy of

$12.6 billion for Fannie Mae on debt and MBS, and $5.9 billion for Freddie Mac. The CBO

numbers represent the incremental value of a year of new business, rather than the value of a 10-

year guarantee on the enterprises. Passmore (2005) reports a present value over 25 years in the

range of $122 to $182 billion as the subsidy to Fannie and Freddie. His estimates are

conceptually similar to the ones reported here, but considerably larger. The closest comparison is

with the results in Table 10, which shows a combined guarantee value of $28 billion over 25

years, or approximately 23 percent of F&F’s combined market capitalization.

5 Ambrose and Warga (2002) and Nothaft (2002) estimate the funding advantage of the GSEs.

27

Several Fannie Mae papers have examined risk using volatility-based methods. Stiglitz et. al.

(2002) conclude that the cost of an implicit guarantee to the government would not exceed $200

million, which is more than an order of magnitude smaller than our estimates. One reason for the

discrepancy is that they rely on the relatively benign historical time series on interest rates and

credit risk of the post-WWII period, rather than using forward-looking stock market prices as the

basis for calibrating volatility. They do not describe the details of their valuation model, but it

appears that they do not consider the possibility of time variation in volatility, nor the possibility

of changing behavior in periods of distress. Hubbard’s (2004) approach has similarities with the

one taken here, although it relies on a different underlying model of assets and liabilities. He

focuses on default probabilities and losses at a one-year horizon, so the analysis cannot be used to

assess the present value of the guarantee.

A possible explanation for the higher subsidy values that emerge from spread-based analyses

versus options-based methods is that the benefit of the implicit government guarantee to the GSEs

is greater than the cost of expected defaults to the government. The difference arises, for

instance, because the agency classification of the debt allows regulated financial institutions to

hold less capital against these investments, and because liquidity, also a valuable if hard to

quantify commodity, is enhanced. The fact that the market places value on other attributes that

accompany the implicit government guarantee means that from an opportunity cost perspective,

the cost to the government includes these other benefits created, and also is greater than the cost

of expected defaults. The estimates here, then, should be considered a conservative estimate of

the cost to the government of the implicit guarantee.

5. Summary and Further Discussion

The analysis suggests several conclusions about the cost and risk of the implicit government

guarantee to F&F. As expected, the present value of the guarantees are far smaller than the

potential losses from a catastrophic outcome, as represented here as by the .5 percent value at risk

of the present value of 10-year costs. The base case estimates show guarantee values over 10

years that total 7.9 billion. The VaR is $74 billion for Fannie, and 48 billion for Freddie. A novel

feature of this analysis is to quantify the effect of correlation between volatility and financial

distress, a feature that significantly increases estimated costs and risk exposure. The analysis also

demonstrates that such a correlation may be present but unidentifiable in historical data because

periods distress leading to high volatility are rare and relatively short-lived. The policy options

28

considered – strengthening capital requirement or increasing oversight – are shown to have very

different effects. Tighter capital requirements could significantly reduce guarantee values, but

have a smaller effect on catastrophic outcomes. Increased oversight in the form of more frequent

monitoring or a tighter shut-down trigger has a minimal effect on guarantee value, but could

significantly reduce the probability of catastrophic losses.

It is important to emphasize what these estimates do, and do not, measure. The estimates

represent the market value of providing credit insurance to F&F’s debt-holders, but not the

economic efficiency loss or benefit resulting from the subsidy. As a first approximation, the

subsidy is a pure transfer to the stakeholders6 in F&F from the government, and hence from

taxpayers at large. The size of any social efficiency losses or gains, such as whether the subsidy

causes overinvestment or reduces underinvestment in housing, cannot be inferred from these

numbers; a fundamentally different type of analysis would be required to assess such questions.

It also should be emphasized that the options-pricing approach takes a narrow view of the value

of the guarantee, abstracting from benefits such as added liquidity or lower associated capital

requirements for the regulated institutions that invest in their securities that increase the market

value of GSE securities. Hence, these estimates are lower than the cost to the government in

terms of opportunity cost, which is a conceptually broader measure of the benefit conferred.

The absolute size of the reported numbers suggests that while financial distress at F&F could be

costly, it is unlikely to be large enough to severely disrupt financial markets. However, poor

management of an evolving crisis could lead to much higher costs and greater market disruption

than is captured in this exercise. As a point of reference, the combined value at risk in most of

the scenarios considered is less in real terms than the cost of the S&L crisis in the 1980s.

To construct a less stylized model, or to better calibrate and evaluate this one, would require

information not currently reported by Freddie or Fannie. Providing more information about

duration and convexity would significantly improve transparency, and imposes a relatively small

additional reporting requirement. Currently, neither Fannie nor Freddie report the separate

duration of assets and liabilities, only the gap between them. Neither reports convexity, either in

public disclosures or privately to OFHEO. The negative convexity associated with mortgages

6 Many of the spread-based analyses cited earlier attempt to tease out the incidence of the subsidy between shareholders and homeowners, usually using information on the spread between conforming and jumbo mortgages. The analysis here does not address this issue.

29

implies that the duration gap is only informative about risk for very small changes in interest rate.

It also implies that losses will increase at a faster than linear rate for large interest rate changes.

The convexity gap is a measure of this divergence that, together with the duration gap, would

provide a more reliable estimate of interest rate and prepayment risk.

Although mortgages are highly collateralized and historically credit losses have been small, F&F

have a highly leveraged exposure to credit risk that is not hedged. Other financial institutions,

including insurers, use reinsurance markets, or increasingly, credit default swaps, to better spread

such risks. An option that has not received much attention is to encourage credit hedging by

F&F.

In considering how the regulation of the GSEs should be changed to limit potential systemic risk,

a number of fundamental considerations that are beyond the scope of this study must also be

taken into account. One is whether government support for Fannie and Freddie on net stabilizes

the housing market. While the increased liquidity of the mortgage market increases the supply of

capital to housing in normal times, it may also encourage excessive investment in housing or

inflation in housing prices that exacerbates problems during periods of heightened risk. Another

open question is whether there are mechanisms that would allow the government to credibly

avoid or lower the expected cost of interventions, for instance by offering a more limited but

explicit guarantee financed by premiums charged to the enterprises.

30

References

Ambrose, Brent, and Arthur Warga. 2002. Measuring potential GSE funding advantages. Journal of Real Estate Finance and Economics 25(2/3): 129-150. Carnell, Richard S. 2005. “Handling the Failure of Fannie Mae and Freddie Mac,” Conference on Receivership Powers, American Enterprise Institute, Discussion Draft Collin-Dufresne, P. and R.S. Goldstein, 2001, “Do credit spreads reflect stationary leverage ratios?”, Journal of Finance, 1929-1957. Congressional Budget Office 2001, “Federal Subsidies and the Housing GSEs” Congressional Budget Office 2004a, “Updated Estimates of the Subsidies to the Housing GSEs” Congressional Budget Office 2004b, “Estimating the Value of Subsidies for Federal Loans and Loan Guarantees” Crosbie, Peter and Jeff Bohn 2003, “Modeling Default Risk,” Moody’s KMV White Paper; available at http://www.moodyskmv.com/research/whitepaper/ModelingDefaultRisk.pdf Falcon, Armando 2004. Statement before the Committee on Banking, Housing, and Urban Affairs, U.S. Senate Feldman, Ron. 1999. “Estimating and managing the federal subsidy of Fannie Mae and Freddie Mac: Is either task possible?” Journal of Public Budgeting, Accounting, and Financial Management 11 (Spring): 81–116. Frame, W. Scott and Lawrence J. White. 2005. “Fussing and Fuming over Fannie and Freddie: How Much Smoke, How Much Fire?” forthcoming, Journal of Economic Perspectives Hubbard, R. Glenn, 2004. “The Relative Risk of Freddie and Fannie,” Fannie Mae papers, Vol. III, Issue 3. Jaffee, Dwight. 2003. “The interest rate risk of Fannie Mae and Freddie Mac,” Journal of Financial Services Research, 24(1): 5-29. Kane, Edward J. and Chester Foster. 1986. “Valuing conjectural government guarantees of FNMA liabilities,” In Proceedings: Conference on Bank Structure and Competition. Chicago: Federal Reserve Bank of Chicago. Leland, Hayne E., “Corporate Debt Value, Bond Covenants, and Optimal Capital Structure”, Journal of Finance, 49 (4), 1994, 1213-52. Merton, Robert C., “On the Pricing of Corporate Debt: The Risk Structure of Interest Rates”, Journal of Finance, 29 (2), 1974, 449—470. Merton, Robert C., “An Analytic Derivation of the Cost of Loan Guarantees and Deposit Insurance: An Application of Modern Option Pricing Theory, Journal of Banking and Finance, 1(1), 1977 (June), 3—11.

31

Naranjo, Andy and Alden Toevs. 2002. “The effects of purchases of mortgages and securitization by government sponsored enterprises on mortgage yield spreads and volatility,” Journal of Real Estate Finance and Economics. 25 (September-December): 173-195 Nothaft, Frank E., James E. Pearce, and Stevan Stevanovic. 2002. “Debt spreads between GSEs and other corporations,” Journal of Real Estate Finance and Economics 25 (September-December): 151:172. Passmore, Wayne. 2005. “The GSE implicit subsidy and the value of government ambiguity,” Real Estate Economics, forthcoming Seiler, Robert S. 2003. “Market discipline of Fannie Mae and Freddie Mac: How do share prices and debt yield spreads respond to new information?” Office of Federal Housing Enterprise Oversight Working Paper 03-4. Sharpe, William F. (1976), “Corporate Pension Funding Policy”, Journal of Financial Economics, 3(3), (June), 183—193. Stiglitz, Joeseph E., Jonathan M. Orsag and Peter Orsag, 2002, “Implications of the New Fannie Mae and Freddie Mac Risk-Based Capital Standards,” Fannie Mae papers, Vol 1, Issue 2.